The Scottish Medicines Consortium (SMC) has released a significant update to its policy paper, the Patient Access Scheme (PAS) Standard Terms (Issued December 2025). This revision, overseen by the Patient Access Scheme Assessment Group (PASAG) within Healthcare Improvement Scotland, refreshes the framework that governs how pharmaceutical companies provide discounts to the health service. The new terms replace the previous 2020 version and apply to all new submissions for both 'Simple' confidential discounts and 'Complex' schemes.
The update formalises the role of the Common Services Agency, operating as National Services Scotland, which acts as the legal agent for every regional Health Board in the country. By using these standard terms, the regulator ensures that a single commercial agreement covers the entire Scottish health system. This removes the need for companies to negotiate separate contracts with individual boards, ensuring that when the SMC recommends a medicine, it can be adopted at a consistent price across all regions without administrative delay.
A major focus of the expansion involves the management of information. Data are now subject to clearer audit requirements to ensure that the rebates paid to the health service are accurate. The terms specify that the Common Services Agency has the right to verify usage figures and patient numbers. These data are plural and must be handled according to strict confidentiality rules, yet they remain essential for the health service to confirm it is receiving the value promised in the initial pricing proposal.
The revised terms also clarify the duration and ending of these agreements. Most schemes are set to run for an initial period of five years, providing a stable financial environment for both the health service and the supplier. If either side wishes to end the arrangement, they must give at least three months' notice. This structured approach helps the health service manage its long-term budget while giving suppliers a clear understanding of their ongoing commitments in the Scottish market.
By providing a fixed legal starting point, these measures reduce the friction often found in price negotiations. The standardisation of these terms means that once a clinical decision is made, the financial mechanics are already in place. This results in a much faster path from a positive recommendation to the point where a medicine is available to patients, as the core contractual risks and responsibilities are settled well in advance of the product launch.
Source: Scottish Medicines Consortium
Link: Patient Access Scheme (PAS) Standard Terms
Date: December 2025